New York Insurance Code 328 – Index number 451685/2020 NYSCEF DOC. number. 358 NYSCEF: 01/18/2022 Supreme Court of the New York Territory for the People of New York State of New York State of New York, Verified Supplemental Petition Organization, INC. . ; DJT HOLDINGS LLC; DJT HOLDINGS MANAGING MEMBER LLC; Seven Enterprises LLC; Eric Bock; Carolus Martapano; Morgan, Lewis; Boccios, LLB; Sherry Dillon; MAZARS USA LLC; DONALD J. BUMP; DONALD BUMP, JR.; AND IVANKA BUCINUM, Plaintiff, v. Defendants. 1 of 115 index numbers
Index number 451685/2020 NYSCEF DOC. number. 358 NYSCEF: 01/18/2022 The State of New York, as in its Verified Supplementary Petition, respectfully alleges: The Trump Organization and Donald J. Trump (“Mr. Trump”) misrepresented the value of Mr. Trump’s assets on an annual basis. Financial statements, tax returns and other documents and material falsifications were made to third parties in order to obtain loan coverage, insurance and other financial and tax benefits. and other relevant laws. The Office of the Auditor General (OAG) identified facts and documents indicating that annual statements, tax returns, and other documents contained material errors and omissions in the investigation. Its purpose is to make the final determination as to who is responsible for those deletions and omissions. The Office of the Auditor General (OAG) is seeking testimony and documentation regarding any Trump Organization employees and associates — and any other entities and individuals — who assisted the Trump Organization and Mr. Trump in the commission of, or may have had relevant knowledge of, the misdeeds and omissions in the case. . Included in the recording of this proceeding, and which is included, is the second affidavit of Matthew Colangelo dated August 21, 2020 (“Section Two), on camera to protect the confidentiality of this ongoing investigation. See Michaelis v. Graziano, 5 N.Y.3d 317, 323 (2005); American Dental Coop., Inc. v. Attorney-General, 127 A.D.2d 274, 280 (1st Dep’t 1987).The Office of the Attorney General (“OAG”) at 2. This investigation is conducted pursuant to New York Executive Code.
New York Insurance Code 328
Index number 451685/2020 NYSCEF DOC. number. 358 NYSCEF DATE: 01/18/2022 January 18, 2022; and its attachments (included) move OAG to compel Donald J. Trump, Donald Trump Jr., and Ivanka Trump to provide testimony, and to compel Donald J. Trump to produce documents in its possession, possession, or control. . Many of the witnesses who participated in the creation and publication of false statements were omissions in this investigation. However, witnesses close to the Trump Organization summit asserted Fifth Amendment rights against self-incrimination. Others reported false memories or claimed to have been trained by older workers. And, as the court is well aware, other evidence and documents have been withheld under lien claims, including claims on behalf of Mr. Trump himself: For example, Sherry Dillon, a defendant in the OAG motion, was Mr. Trump’s personal tax advisor. To Mr. Trump himself. See, for example, Kirschner v. KPMG LLP, 15 NY.3d 446, 465-66 (2010). But Mr. Trump’s actual knowledge of himself and his intent to do so — the many errors and omissions made by him or on his behalf — are essential parts to correctly and properly resolving the OAG investigation. Also Donald Trump Jr. and Ivanka Trump acted as agents for mr. Trump has, on his own terms, supervised the actions of others here; Their certification is also essential for the timely achievement of the OAG. Specifically respondents: 4. On top of this supplemental application is verification. In connection with Colin Varty’s assertion, 5. As detailed below, the Office of the Auditor General (OAG) has obtained documents and affidavits 6. The knowledge and actions of Mr. Trump’s agents and proxies can be attributed 7. For all these reasons, work is being increased. Of these, the testimony of 3n. 115 2.
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Index number 451685/2020 NYSCEF DOC. number. 358 NYSCEF: 01/18/2022 8. Reply to Donald J. Trump. Mr. Trump is the owner of the interesting Trump Organization. He had primary authority over the Trump Organization’s employment profile related to transactions with counterparties, including financial institutions, and the Internal Revenue Service. The Trump Organization has responded to the OAG document and subpoenas, issuing more than 930,000 documents. Although about a dozen current and former Trump Organization employees have testified before OAG, and Mr. Trump personally provided production of federal income tax information to OAG, Mr. Trump himself refused to comply with OAG’s subpoenas for documents and evidence, and proceeded to crush. Subpoenas in this proceeding and (along with the Trump Organization) seek to order this entire case in a suit recently filed in the District of New York, United States. This court requires Mr. Trump to testify before the Office of the Auditor General and submit relevant documents in the possession, custody or control of the Office of the Auditor General. 9. Answer Donald Trump Jr. Donald Trump Jr. He runs the Trump Organization with Eric Trump. He is also the trustee of the Donald Trump Revocable Fund and is responsible for the annual financial statements relating to the assets held by the fund for his father. Since 2017, Donald Trump Jr. has the power to make many economic decisions that include deception in the valuation of assets. Donald Trump Jr. Must be OAG certified. 10. Responding to Ivanka Trump. In response, Ivanka Trump was the Executive Vice President of Development and Acquisitions for the Trump Organization until at least 2016. Among other assignments, Mrs. Trump has negotiated and secured financing for Trump Organization properties. Until January 2017, Ms. Trumpet was the first contact for Trumpet 4 of 3 115
Index number 451685/2020 NYSCEF DOC. number. 358 NYSCEF Admitted: 01/18/2022 The largest creditor of the organization, Deutsche Bank. In connection with this work, Mrs. Trump provided misleading financial statements to Deutsche Bank and the federal government. Ivanka Trump will have to testify before the OAG. 11. C.P.L.R. 2308(b) to enforce its briefs without further delay and therefore respectfully request that the Court grant OAG’s entire application and deny Defendant’s application. freeview. Section 12. The Attorney General is responsible for the supervision of the activities of NYU and its directors and officers, in accordance with the New York Executive Code and other applicable laws. It is expressly carried out in the legislature with vicious deception and illegal business dealings. See, for example, Executive Code § 63 (12). 13. Respondent Donald J. Trump is the beneficial owner of a group of entities he calls the “Trump Organization.” As previously alleged, according to Required Disclosures, from May 1, 1981, to January 19, 2017, Mr. Trump served as a director and chairman of the Trump Organization, Inc. From at least July 15, 2015 through May 16, 2016, Mr. Trump was the sole owner of The Trump Organization, Inc. Since 2017, the Trump Organization, Inc. It is wholly owned by DJT Holdings Managing Member LLC. For your information and belief, Mr. Trump is the sole beneficiary of the Donald J. Trump Returnable Fund, a fund created and operated under the laws of New York, and is the legal owner of the above assets. 1 quotes on ex. __They are exact copies of reference documents that accompany Colleen Faherty’s affidavit, dated January 18, 2022, and filed with this petition. Some extracts are provided for this assertion in order to avoid extraneous material being submitted to the court. At the request of the parties, the Court granted OAG permission to submit sealed documents containing investigative information. File number 356. 5 of 115 4
Index number 451685/2020 NYSCEF DOC. number. 358 NYSCEF received: 01/18/2022 14. In response to Donald Trump, Ir is Executive Vice President of The Trump Organization. According to The Trump Organization, Donald Trump Jr. Eric Trump, who took over the Trump Organization from Mr. Trump in 2017, replied. Donald Trump Jr. Trumpet manages the organization’s property portfolio and is involved in all aspects of the company’s property. Development of Donald Trump Jr. and former The Trump Organization CFO Allen Weisselberg were trustees of the Donald J. Trump Revocable Trust until Mr. Weisselberg resigned in June 2021. As of October 29, 2021, Donald Trump Jr. Donald J Trumpett’s Revocable Trust. 15. Respondent Ivanka Trump was Executive Vice President, Development and Acquisitions of the Trump Organization until at least 2016. Among other duties, Mrs. Trump negotiated and obtained financing for Trump Organization properties. While at the Trumpet Organization, she “directed  ‘all areas of the company’s real estate and hotel boards.'” In addition to “participation in all provisions – large and small.”